NCP Community Involvement Requirements and Additional Recommendations

1. NCP Community Involvement Requirements and Additional Recommendations Katy Miley, R7 OSC

2. Course Agenda • Requirements and recommendations for CI on your removal site • NCP required CI activities, deliverables, and timelines for removal actions • Administrative Records • Recommended CI activities • OSC/CIC/media relations coordination • Case study example • Guidance on developing effective presentations and engaging audiences

3. Removal Activity CI Requirements • Reference document • Removal Process Community Involvement Activities handout

4. Removal Activity CI Requirements • Designate a lead agency spokesperson • OSC • Community Involvement Coordinator • Press Officer • Public Information Officer • ICS

5. Removal Activity CI Requirements • Time-Critical • Removal with Planning Period < Six Months • Establish an administrative record (AR) and make AR file available for public inspection in repository NLT 60 days of initiation of on-site activities • Establish a local repository at or near location of response action and publish notice in local paper of AR file availability within 60 days of initiation of on-site activities • As appropriate, provide a 30 day public comment period on AR file and include response to comments received during comment period in the AR file

6. Removal Activity CI Requirements • Non-Time Critical • Removal with Planning Period ≥ Six Months • Establish an administrative record (AR) • Establish a local repository near site location and place AR file in repository no later than the signing of the EE/CA approval memorandum • Conduct an EE/CA or its equivalent that includes community interviews and preparation of a CIP/CRP prior to EE/CA completion • Publish notice in local paper of availability and description of EE/CA and publish notice of AR availability • Allow a 30 day comment period on selection of removal action and prepare written response to significant comments

7. Removal Activity CI Requirements • Removal with On-Site Action Expected to Last >120 Days: • Time-critical or non-time critical • Establish an administrative record (AR) and establish a local repository near site location • Conduct community interviews and prepare a Community Involvement Plan (CIP) by the end of initial 120 days of site work • Place AR file in repository by the end of the initial 120 days of site work • Publish notice in local paper of AR file availability

8. Removal Activity CI Requirements • Emergency • Removal where on-site activities are initiated within hours of determination and cease within 30 days • Establish an administrative record (AR) and make available for public inspection in at central location • Make AR file available NLT 60 days of start of on-site activities and publish notice in local paper of AR file availability • As appropriate, provide a 30 day public comment period and include response to comments received during comment period in the AR file

9. The Administrative Record • Reference Documents • AR removal guidance flowchart • 2010 – Revised guidance on compiling administrative records for CERCLA response actions • Published FR notice direct final rule 11.7.12

10. The Administrative Record • What is it for? • To provide the public the information that EPA used to make a decision • To provide the public an opportunity to comment on the decision, as appropriate • What goes in it? • Information used to make the decision and CI documents • Pictures • State reports • Site assessment data • CIP

11. The Administrative Record • How is it developed? • Determine site documents that were considered for the decision • Request an AR through your regional records center • Where does it go? • Removals • Central repository and repository near your site • Stop by the library near site and get a business card • Emergencies • Central repository – i.e. EPA Regional Office

12. Removal Activity CI Recommendations • Build your site team • OSC • Counsel • CIC • Technical Team • Toxicologist/Risk Assessor • SSC • Other Federal Partners • ATSDR, USACE

13. Removal Activity CI Recommendations • Know your site • Develop a site summary • Site background • Contaminants of concern • Cleanup plans • Site team members • Superfund ID numbers • Provide site summary to your CIC • Summary = Fact sheet • Provide site summary to your counsel • Counsel can assist with access agreements and other negotiations

14. Removal Activity CI Recommendations • Know your communication objectives and issues • Gain access? • Resolve conflict? • Get input? • Provide information/increase awareness? • Know your community/audience • Rural/urban/EJ • Residents/workers/local business owners • City officials/elected officials/media

15. Removal Activity CI Recommendations • Know your message • Data results from sampling activities • Locations where work may be conducted • Long term site plan • Know your communication techniques • Fact sheet • Availability session/open house/public meeting • Power points • Maps • Charts • Social media

16. Summary • CI requirements for Removals in the NCP are distributed and cross referenced through Section 300 • 300.415, 300.800, 300.820 • For successful CI you may need to consider additional community engagement activities • Be creative and pro-active • Engage your regional office of public affairs and other site team members early and often